Market

Who does Law No. 5-A/2026 (Lei n.º 5-A/2026) actually reach? Two maps answer that question: the five registrant categories of the Transparency Register of Interest Representation (Registo de Transparência da Representação de Interesses — RTRI) and the eight categories of public entities within scope.

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The five registrant categories — Article 13(3)

Every entity that registers in the RTRI falls into one of five categories, and the category shapes both the registration content and the typical compliance needs.

a) Private social partners and entities subject to mandatory consultation

Private social partners, entities represented in the Economic and Social Council and entities whose hearing is constitutionally or legally mandatory. Their registration is automatic and ex officio (Article 13(4)) — but the duties of conduct and disclosure still have to be operationalised internally.

b) Representatives of third-party interests

Public affairs consultancies and professionals who represent clients. The most demanding segment: enumeration of clients, interests and sectors (Article 5(1)), the record of contractual relationships (Article 7(2)) and the 60-day registration window of the transitional regime (Article 19(2)).

c) Representatives of business interests

Companies with institutional relations of their own — regulated sectors, infrastructure, energy, health, technology — that engage public entities in their own name and need policies, records and trained teams.

d) Institutional representatives of collective interests

Business and sector associations, NGOs and think tanks representing collective causes, which combine advocacy with the new duties of identification and conduct.

e) Other representatives

A residual category capturing every other entity whose activity fits the definition of Article 2(1) — the first step here is always the scoping assessment.

The eight public entity categories — Article 3

On the other side of the relationship, eight categories of public entities assume duties of disclosure, consultation pages and legislative footprint (pegada legislativa) mechanisms (Articles 8 to 10):

the Presidency of the Republic;
the Assembleia da República (the Portuguese Parliament);
the Government;
the self-government bodies of the autonomous regions;
the Representatives of the Republic for the autonomous regions;
the bodies and services of the direct and indirect administration of the State;
the Bank of Portugal, independent administrative entities and regulatory authorities;
the bodies and services of the autonomous, regional and local administration, including their offices and the inter-municipal entities.

For the local government segment the ecosystem provides a specialised domain, lobbyingmunicipal.pt; foreign entities interacting with Portuguese public entities are served through the international gateway representacaodeinteresses.com.

Which category are you in?

If the answer is not obvious, that is exactly what the compliance diagnostic determines — category, obligations and a prioritised plan.

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